OPINION
SWIFT, Judge:
After trial on March 5, 1993, the parties were asked by the Court to submit briefs on one of the primary legal arguments made by petitioner herein; namely, whether respondent is barred by collateral estoppel from contesting the value of certain master educational audio tapes (master audio tapes) as found by a Federal District Court in an injunction proceeding under sections 6700 and 7408.
Respondent determined deficiencies...
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